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III. Comments - Compliance Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inppection and the facts or evidence supporting the enforcement action. In addition the. operator had installed a culvert beneath the road running between the blackwater pond and Pond 1 which was not on the map. This culvert's inlet area was 80X clogged (III.C). Ditch CD-3 drains north and south into a central grate from the western perimeter of the coal stockpile. The ditch was not in place but the grate was open (I.C.). There was a shallow unmarked ditch on the south side of the road leading between the coal processing facility and County Road 92 (II.a.). The culvert draining from the westernmost grate into the drainage routing junction was also unmapped on Map 20 (III.a.). The final ditch in the mine site area.ran along the refuse pile access road. This ditch was closed immediately north of the shop by poor grading and was also closed around the first bend above the steep grade sign (I.h.). The northernmost inlet culvert on Pond 5 was a third closed at its inlet. The operator was asked to clean it as part of NOV 91-29 (IV.4). The train loadout was visited on Thursday, December 19. The loadout fs divided into two areas, the East Loadout and the West Loadout. The East Loadout's drainage design consisted of a ditch along the north disturbance boundary draining into the pond, a containment ditch around the topsoil stockpile, and a ditch south of the tracks. The northern ditch was not functional on the western end because the top of the ditch was higher than the loadout due to improper grading (I.f.). This ditch had not been rip-rapped in the short steep stretch running south to north (I.h.) and the ditch then split into two ditches to minimize disturbance to a short band of undisturbed area. The southernmost ditch here was not marked on the map (II.c.). Its installation was certainly a good idea; it just needs to be designed. A ditch had been cut north of the tracks, rather than south-of the tracks as shown on the Map 13 (II.b.). The coal fines south of the track had blackened this undisturbed area. It was unclear whether these resulted from wind deposits or from sloppy train loading. Mr. Weaver later suggested that the wide area south of the tracks may have been used for a truck turn-around. The map showed this area draining into a sediment trap (I.g.). In any case, several years ago, Mr. Jim Stevens, MLRD, had asked that the area be directed into the pond. This inspector studied it and the designs to August, 1991, and told the operator to direct it offsite as the pond was inadequately designed to handle the flow. At the time of the discussion, Mr. Weaver committed to cleaning the area of fines. The drainage shunt was closed, but the area was never cleaned. As a Consequence, NOV 91-35 was written for failure to pass disturbed area runoff through a sediment pond. A sediment trap was present on the southwest end of the east loadout (II.d.). This had not been mapped, nor were there any design calculations. The west train loadout consisted of a perimeter berm on the south side of the disturbed area, below the railroad fill, and a ditch running west through the center of the loadout immediately south of the terrace. The perimeter berm had settled, was heavily vegetated, and barely visible unless one walked on it. Some time ago, 1n two locations, coal had spilled down from above, and partially filled the depression formed by the berm (I.d.). Due to the limited height of the berm, the operator was asked to clean these locations out. The central ditch had just been cut by a graded operator, who left berms on both sides of the ditch. Water would not be able to flow north into the ditch, and water flowing south would knock sediment into the ditch. For ali intents and nnrnncoc 1•hic rii l•rh vac nnfnnrhinnal (T o 1